The country of origin of a recoil spring assembly

N357198 January 13, 2026 OT:RR:NC:N1:103 CATEGORY: Origin Youngwon Yoon W Customs 209 Hakdongro Gangnamgu, Seoul 06052 South Korea RE: The country of origin of a recoil spring assembly Dear Youngwon Yoon: In your letter dated December 19, 2025, you requested a country of origin ruling on behalf of your client, Hyundai Minuteness Co., Ltd. The merchandise under consideration is referred to as a recoil spring assembly, part number 14737811, and is described as a component used in the undercarriage of an excavator. Its primary function is to maintain constant tension in the crawler track system and to absorb any impacts. The main components of the assembly include a coiled spring, a yoke, and an adjustable hydraulic cylinder mechanism (composed of a body cylinder, rod, and seals). The assembly process will occur in South Korea using components from Korea and China. Besides a tension support that is sourced from China, all of the components are sourced domestically in Korea, including a body cylinder, a spring, a yoke, a rod, a nut, a bracket support, a stop, various seals, and fasteners. These components are created in Korea from raw materials or basic metal shapes. For example, the body cylinder and yoke are forged from SM45C-M2 steel. The rod and nut are formed from steel bars. The stop, which is a physical barrier that limits travel, is formed from steel pipe. After the rough shapes of each component are formed, they are machined using a combination of turning, drilling, tapping, grinding, and milling operations. Final assembly involves assembling the individual components into the recoil spring assembly and securing them using fasteners. The operational steps are described as seating the seals into the body cylinder, inserting the rod, and screwing a valve into a threaded opening on the body. Next, a worker adds the stop, spring, and yoke before securing all of the components in place using the tension support, a nut, and a washer. Lastly, the assembly is painted before export. When determining the country of origin for purposes of applying current trade remedies under Section 301 and additional duties, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter H301619, dated November 6, 2018. The test for determining whether a substantial transformation will occur is whether an article emerges from a process with a new name, character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc. v. United States, 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993). Based upon your description of the manufacturing operations, we note that virtually all of the components of the recoil spring assembly are manufactured in South Korea. After processing, these components emerge with a new name, character, and use, different from that possessed by the materials (e.g., steel bars, steel pipes, and raw materials) from which they were formed. Thus, based on the totality of the circumstances, the country of origin of the recoil spring assembly, part number 14737811, will be South Korea. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection Regulations (19 C.F.R. 177). A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, please contact National Import Specialist Paul Huang at paul.huang@cbp.dhs.gov. Sincerely, (for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division